Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Permanent Establishment (‘PE’) in India - equipment PE - It cannot be denied that the ‘vessel’, on which equipments were placed and personnel was stationed, as fixed place of business through which business is carried on by assessee. Thus condition for PE stands satisfied
Permanent Establishment (‘PE’) in India - equipment PE - It cannot be denied that the ‘vessel’, on which equipments were placed and personnel was stationed, as fixed place of business through which business is carried on by assessee. Thus condition for PE stands satisfied
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